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Drafting, Pleadings and Appearances · Adjudications and Appeals under SEBI Laws

Appeals to the Securities Appellate Tribunal (SAT) Against SEBI Orders

Updated 11 October 2026 · Fact-checked

Any person aggrieved by a SEBI order or an adjudicating officer's order can appeal to the Securities Appellate Tribunal (SAT). Under section 15T of the SEBI Act, the appeal must be filed within 45 days of receiving the order, in the prescribed form with the prescribed fee. SAT may condone delay for sufficient cause.

Understand Appeals to the Securities Appellate Tribunal

SEBI makes orders and its adjudicating officers impose penalties. A person hit by such an order needs a forum to challenge it. That forum is the Securities Appellate Tribunal (SAT). It is a specialised tribunal, so securities disputes are decided by a body that knows the market.

The main provision is section 15T of the SEBI Act, 1992. Any person aggrieved by (a) an order of the Board made on or after the commencement of the Securities Laws (Second Amendment) Act, 1999, under the Act or its rules or regulations, or (b) an order of an adjudicating officer, may appeal to a SAT having jurisdiction in the matter. Section 15T(1)(c) also covers certain orders of the Insurance Regulatory and Development Authority and the Pension Fund Regulatory and Development Authority.

The same pattern appears in other securities laws. Section 23A of the Depositories Act, 1996 gives an appeal to SAT against a Board order made on or after the 1999 amendment, and against an adjudicating officer's order under that Act. Section 23L of the Securities Contracts (Regulation) Act, 1956 gives an appeal against an order or decision of a recognised stock exchange, an adjudicating officer, or a SEBI order under section 4B or section 23-I(3).

The older sections, section 20 of the SEBI Act and section 23 of the Depositories Act, gave an appeal to the Central Government. They now apply only to Board orders made before the 1999 amendment commenced. Do not cite them for a present-day appeal.

SAT has a duty to hear both sides, then pass such orders as it thinks fit, confirming, modifying or setting aside the order appealed against. It should try to dispose of the appeal within six months of receiving it. A further appeal on a question of law lies to the Supreme Court, which is covered in a separate topic.

Key rules to remember

Who may appeal (SEBI Act, s. 15T(1))
Any person aggrieved by (a) a Board order made on or after the 1999 amendment, (b) an adjudicating officer's order, or (c) certain IRDAI or PFRDA orders → appeal to SAT
The appellant must be a person aggrieved. The Board itself is not the appellant against its own order.
Limitation (s. 15T(3); Depositories Act s. 23A(3); SCRA s. 23L(2))
Appeal within 45 days from the date the copy of the order is received
Time runs from receipt of the copy, not from the date of the order. Section 15T(3) names the Board, the adjudicating officer, IRDAI or PFRDA. Section 23A(3) of the Depositories Act, as worded, refers to the copy of the order made by the Board. On the face of that text, the starting point for an appeal against an adjudicating officer's order under that Act is not spelled out. Section 23A(1) still allows that appeal.
Condonation of delay
SAT may entertain a late appeal if satisfied there was sufficient cause
The appellant must show sufficient cause for the delay.
Form and fee
Appeal in such form and with such fee as may be prescribed
Form and fee are set by rules, not fixed in the Act.
Procedure on appeal (s. 15T(4))
Opportunity of being heard to the parties → SAT passes orders confirming, modifying or setting aside the order
Hearing both sides is mandatory.
Copy of SAT order (s. 15T(5))
SAT sends a copy of every order to the Board, the parties and the concerned adjudicating officer
IRDAI or PFRDA also receive a copy where the appeal arose from their order.
Disposal time (s. 15T(6))
Dispose of the appeal finally, as an endeavour, within six months from receipt
This is a direction to endeavour, not a strict bar.
Exchange refusal to list (SCRA s. 22A)
Company may appeal to SAT within 15 days of being furnished reasons for refusal to list
The period differs from the 45-day rule.
Delisting (SCRA s. 21A(2))
Listed company or aggrieved investor may appeal within 15 days of the delisting decision; further period up to one month if sufficient cause
Delisting needs a reasonable opportunity of being heard before the decision.
Old route (SEBI Act s. 20; Depositories Act s. 23)
Appeal to the Central Government, only against Board orders made before the 1999 amendment commenced
Mention only to contrast with SAT.

How to solve Appeals to the Securities Appellate Tribunal questions

Use this method for any question on an appeal against a SEBI or related order.

  1. 1Identify the order and who made it: the Board, an adjudicating officer, a stock exchange, IRDAI or PFRDA.
  2. 2Pick the governing Act and section: SEBI Act s. 15T, Depositories Act s. 23A, or SCRA s. 23L, 22A or 21A.
  3. 3Check the date of the order against the 1999 amendment. Pre-amendment Board orders go to the Central Government under the old sections.
  4. 4Test whether the client is a person aggrieved.
  5. 5Compute the limitation period from the date the copy of the order was received, and decide whether condonation is needed.
  6. 6State the form, fee and documents: appeal in the prescribed form, with the prescribed fee and a copy of the order.
  7. 7State what SAT does: hears the parties, then confirms, modifies or sets aside, and sends copies of its order.
  8. 8Conclude with the advice or the draft: file within time, or file with an application showing sufficient cause.

Quickest way: Four-line check for SAT appeal questions

When to use it: Use when the question gives dates and asks whether an appeal is maintainable or in time.

  1. Write the order type and the section: s. 15T, s. 23A or s. 23L.
  2. Limitation is 45 days from receipt of the copy; for listing refusal (s. 22A) or delisting (s. 21A(2)) it is 15 days instead.
  3. Count the days from the date of receipt and state in time or late.
  4. If late, add that SAT may entertain the appeal for sufficient cause, and draft the ground.

Common mistakes in Appeals to the Securities Appellate Tribunal

  • Citing section 20 of the SEBI Act as the present appeal route.

    Students search for section 20 and stop at the heading Appeals.

    Fix: Section 20 now covers only Board orders made before the 1999 amendment, with appeal to the Central Government. For present orders, cite section 15T.

  • Counting 45 days from the date of the order.

    Students assume limitation starts when the order is made.

    Fix: The text says 45 days from the date a copy of the order is received. Use the date of receipt.

  • Treating the 45-day limit as absolute.

    The word within sounds final.

    Fix: The proviso lets SAT entertain a late appeal if it is satisfied there was sufficient cause. Mention it and the grounds.

  • Applying 45 days to every securities appeal.

    Students generalise the rule.

    Fix: An appeal against refusal to list under SCRA s. 22A(1)(a) must be filed within 15 days of the date the reasons are furnished. An appeal against delisting under s. 21A(2) must be filed within 15 days of the exchange's decision. The one-month further period under s. 22A(1)(b) applies only where the exchange has failed to dispose of the listing application in time. For delisting appeals, the proviso to s. 21A(2) allows a further period of up to one month if sufficient cause is shown.

  • Forgetting that SAT must give the parties a hearing and may only confirm, modify or set aside.

    Students write only the filing steps.

    Fix: Always close with SAT's powers on hearing and the duty to send copies of its order.

  • Stating the six-month disposal period as a binding deadline.

    The figure is remembered without its wording.

    Fix: The Act says endeavour shall be made by it to dispose of the appeal finally within six months. Use the word endeavour.

Worked examples

Example 1

Meridian Securities Pvt Ltd received a copy of an adjudicating officer's order under the SEBI Act on 10 March, imposing a penalty. It wants to challenge the order. Advise on the forum, the time limit and the last date for filing.

Show the solution
  1. The order is by an adjudicating officer, so section 15T(1)(b) of the SEBI Act applies. A person aggrieved may appeal to the SAT having jurisdiction.
  2. Limitation under s. 15T(3) is 45 days from the date the copy of the order is received. Receipt was on 10 March.
  3. In computing the period, the day of receipt is excluded. Day 1 is therefore 11 March.
  4. Count from 11 March: the remaining days of March are 21 (11 to 31 March). The balance is 45 − 21 = 24, so the 24th day of April is the 45th day.
  5. Last date is 24 April. The appeal must be in the prescribed form with the prescribed fee.
  6. If the company misses 24 April, SAT may still entertain the appeal if it shows sufficient cause for the delay.

Answer: Meridian may appeal to SAT under section 15T within 45 days of receipt of the copy, so the last date is 24 April. After that, it needs SAT to condone the delay for sufficient cause.

Example 2

Kaveri Industries Ltd's application to list its shares was refused by a recognised stock exchange. The reasons for refusal were furnished to the company on 5 June. Can it appeal, to whom, and within what time? Would the 45-day period apply?

Show the solution
  1. The exchange refused to list securities under its bye-laws. Section 22A of the SCRA entitles the company to be furnished with reasons, and then to appeal.
  2. The appeal lies to the Securities Appellate Tribunal having jurisdiction.
  3. The time limit under s. 22A(1)(a) is 15 days from the date reasons are furnished. The 45-day period of s. 23L is not the rule for this specific refusal.
  4. Counting from 5 June, excluding the day the reasons were furnished, day 1 is 6 June and the 15th day is 20 June.
  5. SAT may, after hearing the stock exchange, vary or set aside the decision. The exchange must then act in conformity with SAT's order. The appeal must be in the prescribed form with the prescribed fee.

Answer: Yes. Kaveri may appeal to SAT under section 22A of the SCRA by 20 June, which is 15 days from 5 June. The 45-day period does not apply to this refusal. SAT may vary or set aside the decision, and the exchange must comply.

Exam tips

  • Open every answer with the section: s. 15T for SEBI Act, s. 23A for Depositories Act, s. 23L, 22A or 21A for SCRA.
  • Present the answer in the paper's format: provision, analysis of the facts, conclusion.
  • Always compute dates from receipt of the copy of the order and show the day count.
  • Mention the sufficient-cause proviso whenever the facts suggest delay.
  • When drafting, include cause title, facts, grounds, prayer, the copy of the impugned order, and the fee.

Practice questions from Adjudications and Appeals under SEBI Laws

Appeals to the Securities Appellate Tribunal in other exams

The same ground in other exams, if you are preparing for more than one or want another angle on it.

Appeals to the Securities Appellate Tribunal: frequently asked questions

What is the time limit to appeal to SAT against a SEBI order?

Under section 15T of the SEBI Act, the appeal must be filed within 45 days from the date the appellant receives a copy of the order. SAT may entertain a late appeal if it is satisfied there was sufficient cause.

Is section 20 of the SEBI Act still used for appeals?

Section 20 provides an appeal to the Central Government, but only against Board orders made before the Securities Laws (Second Amendment) Act, 1999 commenced. Orders made after that go to SAT under section 15T.

Does the Depositories Act have its own appeal provision to SAT?

Yes. Section 23A of the Depositories Act allows a person aggrieved by a Board order made on or after the 1999 amendment, or by an adjudicating officer's order under that Act, to appeal to SAT. Section 23A(3) fixes 45 days, but as worded it runs from receipt of a copy of the order made by the Board. The text does not separately state the starting point for an adjudicating officer's order, so in an answer, state this and rely on the receipt-of-copy principle. SAT may entertain a late appeal if it is satisfied there was sufficient cause.

How quickly must SAT decide an appeal?

SAT must deal with the appeal as expeditiously as possible and endeavour to dispose of it finally within six months of receiving it. It is an endeavour, not a strict deadline.